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4 critical materials scored · binding chokepoint: Dysprosium (🇨🇳 CN 99% of refining) · 68 restrictive government measures on record
Shin-Etsu Chemical Co., Ltd. produces 2 of the 4 scored materials above (Neodymium, Silicon). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. The remaining 2 (Dysprosium, Terbium) are genuine buyer dependencies and drive the mitigations below. The two sides are reported separately and never netted against each other.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-05) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Dysprosium — 🇨🇳 CN controls 99% of global refining. On this company's production footprint that scores 92/100 (adversarial chokepoint; global 88). The register holds 68 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Dysprosium Shin-Etsu Chemical Co., Ltd. is the 153rd-most-exposed of the 271 named companies we track on 🇨🇳 CN's Dysprosium chokepoint; the most-exposed is TdVib (95/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Shin-Etsu Chemical Co., Ltd. ranks 1st of 100 verified chemicals companies.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 13 further chemicals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 89/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 4 scored materials. Buyer-relative (first-order): weighted by where the company produces (JP 46% · US 36% · CN 12% · AU 5%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Shin-Etsu Chemical (4063.T) is Japan's largest chemical company and one of the world's most diversified specialty-materials groups (~¥2.57 trillion revenue, FY2026). It operates across four segments: Electronics Materials (~36% of sales) — semiconductor silicon wafers and NdFeB rare-earth permanent magnets; Infrastructure Materials (~40%) — PVC resin and caustic soda, primarily through Shintech (Louisiana, USA), the world's largest single PVC producer; Functional Materials (~17%) — silicones and silicon metal; and contract processing services. Shin-Etsu is a leading producer of semiconductor silicon wafers (no primary source for a market-share figure) and is Japan's leading sintered NdFeB magnet manufacturer.
largest silicon wafer supplier in a duopoly with SUMCO. Its supply chain runs from high-purity silica rock through silicon metal production (Australia) to polysilicon (99.999999999% purity, in-house) to finished wafer. Concentration risk sits at the raw-silica mining stage (select global mines) and at polysilicon conversion, though Shin-Etsu's vertical integration substantially internalises this. Any disruption to high-purity silica supply or to the Australia silicon-metal operation propagates directly to wafer output.
segment produces sintered NdFeB magnets sold into EV drive motors, industrial servos, HVAC compressors, and camera autofocus systems. Neodymium (and praseodymium) form the primary alloy matrix. Shin-Etsu built a 3,000 MT/yr rare-earth alloy plant in Longyan, Fujian, China (opened 2013) and backs alternative sourcing in India (neodymium processing) and Vietnam (magnet recycling). China's dominance of upstream rare-earth separation (~85–90% of global NdPr separation) is the structural concentration risk.
for EV traction and industrial servos require dysprosium to maintain coercivity above ~80 °C. China controls ~99% of heavy rare-earth separation. Corrected 2026-08-28: China's export-licensing controls on dysprosium and terbium date to April 4, 2025 (initial 7-element control list), not December 2025; a separate rule effective December 1, 2025 added an extraterritorial 0.1% de-minimis licensing requirement covering rare-earth permanent magnets made outside China with Chinese-origin content. Chinese customs data show zero shipments of dysprosium and terbium oxide to Japan in January, February, March and April 2026 (no cause is stated in the source). Media (citing an anonymous Western customer, company declined to comment) reported in May 2026 that Shin-Etsu had stopped accepting new orders for dysprosium-containing magnets; Shin-Etsu has not officially confirmed this, so it is reported, not confirmed. In June 2026 Shin-Etsu announced a >¥35bn rare-earth refinery in Fukui Prefecture (~50% government-subsidized, targeting dysprosium/terbium/yttrium, commissioning 2029–2031) as a mitigation. Shin-Etsu's grain-boundary diffusion (GBD) technology reduces Dy usage per magnet by up to 50%, providing a partial buffer, but does not eliminate the dependency.
interchangeably with or alongside dysprosium in the highest-performance NdFeB grades (EV motors, wind turbine generators). Covered by the same Chinese export-control regime as dysprosium (see above) — subject to the same April 2025 control listing, the December 2025 de-minimis licensing rule, and the zero terbium-oxide shipments to Japan in January-April 2026. Concentration and substitution risk are substantially identical to dysprosium.
1. Shin-Etsu IR / Annual Reports: https://www.shinetsu.co.jp/en/ir/ir-data/ir-annual/ 2. Neodymium magnet product page (official): https://www.shinetsu.co.jp/en/products/electronics-materials/neodymium-magnet/ 3. Silicon wafer product page (official): https://www.shinetsu.co.jp/en/products/electronics-materials/silicon-wafers/ 4. China rare-earth export control timeline (April 2025 listing; Dec 1, 2025 de-minimis rule): https://www.china-briefing.com/news/chinas-rare-earth-export-controls-impacts-on-businesses/ 5. Zero dysprosium/terbium oxide shipments to Japan, Jan–Apr 2026, and Fukui refinery plan: https://discoveryalert.com/rare-earth-refining-japan-shin-etsu-supply-chain-2026/ 6. Shin-Etsu order-suspension report (unconfirmed by company), May 22, 2026: https://www.kitco.com/news/off-the-wire/2026-05-22/china-squeezes-japan-over-rare-earths-repeat-2010-showdown 7. Shareholder/ownership data (as of 2026-10-02; replaces dead investing.com link, 403): https://finance.yahoo.com/quote/4063.T/holders/
From the company’s own filings and dated disclosures — top-5 concentration and related-party tables where the filer’s regime compels them, named supply and offtake agreements where it does not. This is a disclosure, not a netting: a named supplier concentration is shown beside the exposure score and never adjusts it. Figures are the fiscal years labelled, not a current snapshot.
Panjiva free supplier page, sample US bill of lading dated 2025-08-23: shipper Simcoa Operations Pty. Ltd. (973 Marriot Road, Wellesley, Bunbury, Western Australia), consignee Shintech Inc. (Houston TX; Shin-Etsu's US subsidiary), 96,440 kg in 95 packages, shipment origin Australia, place of receipt Wellesley, lading Shanghai (transshipment), unlading Baltimore, MSC Darwin VI, BoL MEDUGT674587, HTS 2804.69 (silicon under 99.99 pct). Two further Simcoa-to-Shintech BoLs listed the same date. Simcoa's smelter is at Kemerton/Wellesley WA and is a Shin-Etsu Chemical group company, hence related_party. Re-checked 2026-10-03 (wake-minerals-buyers, step 0.5): source_url still live, still shows Simcoa Operations as shipper and Shintech Inc. as consignee for the 2025-08-23 Wellesley(AU)->Shanghai->Baltimore route, three BoLs that date -- confirmed, no change.
Alternative track — a counterparty read from primary filings, never merged into the exposure score. Absence of a name is not absence of a relationship: Filers name only the counterparties their regime compels them to name, and several of this company’s largest are disclosed by size with no name at all.
Ranked by buyer-relative risk, highest first.
4 of 4 of your scored CRMA-strategic materials breach the EU’s own Art. 5 65% single-third-country ceiling (global-production proxy).
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Dysprosium | 🇨🇳 CN 99% refining | 92 | 88 | Critical | EXCEEDS 99% | Low | none | 51 | ▲ rising |
| Terbium | 🇨🇳 CN 99% refining | 90 | 84 | Critical | EXCEEDS 99% | Low | limited | 51 | ▲ rising |
| Neodymium | 🇨🇳 CN 85% refining | 80 | 72 | High | EXCEEDS 85% | Med | some | 50 | ▲ rising |
| Silicon | 🇨🇳 CN 80% refining | 71 | 64 | High | EXCEEDS 80% | High | limited | 19 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Dysprosium | 4 | 5 | 5 | 5 | 3 | company input |
| Terbium | 4 | 5 | 5 | 4 | 3 | company input |
| Neodymium | 4 | 4 | 5 | 3 | 3 | company input |
| Silicon | 4 | 4 | 1 | 4 | 4 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
+ 53 more in the register.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Counterfactual: the rare-earth licensing regime tightens from case-by-case approval to supply suspension on a named geopolitical trigger (the precedent is the 2024-12-03 MOFCOM Ga/Ge/Sb full-ban-on-US escalation that followed BIS HBM controls 24 hours earlier). Direct-hit lines are basket issuers whose binding material is Nd, Pr or Dy with controller = CN.
Modelled buyer-relative move on the binding exposure if this precedent escalates: 92 → 94 (+2) — a relative official policy-pressure magnitude, not a price drawdown.
🇨🇳 CN has issued 4 restrictive actions on Dysprosium since 2024 — cadence accelerating (mean gap 483d → 152d), severity flat (3.5 → 3.5).A descriptive trajectory of past official actions — not a forecast.
You hold exposure to 4 of these 27 materials (Silicon, Neodymium, Dysprosium, Terbium) — your binding Dysprosium exposure is one of them.
Demonstrated cadence: 🇨🇳 CN has widened its restricted-material list a median of 5.8 months apart across 6 distinct restriction dates since 2021 (n=5 intervals).
Response coupling: when 🇨🇳 CN restricts, our causal register records these counter-moves —
Second-order exposure cascade: the retaliation to one chokepoint has historically landed on another material you depend on —
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Dysprosium — 🇨🇳 CN escalates dysprosium controls to a full export-licensing / ban regime | 92 | 94 | +2 |
| Concentration | Dysprosium — 🇨🇳 CN becomes the single source for dysprosium — the second source is lost (full 99%+ monopoly) | 92 | 93 | +1 |
| Policy | Terbium — 🇨🇳 CN escalates terbium controls to a full export-licensing / ban regime | 90 | 92 | +2 |
| Concentration | Terbium — 🇨🇳 CN becomes the single source for terbium — the second source is lost (full 99%+ monopoly) | 90 | 90 | 0 |
| Policy | Neodymium — 🇨🇳 CN escalates neodymium controls to a full export-licensing / ban regime | 80 | 84 | +4 |
| Concentration | Neodymium — 🇨🇳 CN becomes the single source for neodymium — the second source is lost (full 85%+ monopoly) | 80 | 88 | +8 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
This assessment identifies 1 significant vulnerability — Dysprosium — each a High/Critical exposure that is hard to substitute and already under at least one in-force restrictive measure. This engages the duty under Art. 24(4) to take mitigating efforts, including assessing diversification of the supply chain or substitution of the material (see Priority mitigations below).
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 2 materials this company buys (the 2 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Bills at introduction (pre-committee) in US historically become law ~5% of the time (n=37,132, GovTrack — 117th–118th Congresses) — a base rate for comparable bills, not a forecast for this one. source ↗
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
The mitigating efforts Art. 24(4) names — diversifying the supply chain and substituting the material — plus the standard levers against a concentrated, policy-exposed input. Prioritise around the binding input chokepoint (Dysprosium). The 2 materials Shin-Etsu Chemical Co., Ltd. produces (Neodymium, Silicon) are excluded from these buyer levers — see the role check in the verdict and the significant-vulnerability conclusion above.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | Yes — 2 scored SRMs on the input side (binding: Dysprosium); 2 further scored SRMs produced, not consumed |
| Manufactures a listed strategic technology | chemicals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2026-09-30; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-06
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.